G.R. No. L-15594; October 31, 1960
RODOLFO CANO, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and HONORATA CRUZ, respondents.

FACTS

The Acting Prosecutor of the Court of Industrial Relations (CIR) filed an unfair labor practice complaint (Case No. 957-ULP) against Emilio Cano, Ariston Cano, and Rodolfo Cano, as officials of Emilio Cano Enterprises. The complaint alleged that the respondents dismissed the complainants (including Honorata Cruz) for refusing to disaffiliate from their union and cease union activities. The respondents denied the allegations, claiming the dismissals were for other reasons. During the proceedings, two complainants moved to be dropped, but the motion was not acted upon. On July 3, 1957, upon a motion filed by the complainant Union’s president, the CIR ordered the dismissal of the entire case. However, on July 9, 1957, counsel for complainants Honorata Cruz and Salvador Labastida filed a motion for reconsideration, arguing that the Union president was not authorized to withdraw their individual complaints. The CIR en banc remanded the case to the trial judge to receive evidence on the motion. After hearing evidence, the trial judge, on March 10, 1958, set aside the dismissal order and reinstated the case as to Honorata Cruz (dismissing it as to Labastida, who joined the respondents). The trial proceeded, and on January 7, 1959, the trial judge found that the dismissal of Honorata Cruz constituted unfair labor practice, ordering her reinstatement with back wages. Emilio Cano died before the decision was promulgated. Rodolfo Cano’s motion for reconsideration was denied by the CIR en banc, prompting this petition for certiorari.

ISSUE

1. Whether the CIR en banc erred in entertaining the motion for reconsideration filed by complainants’ counsel without the intervention of the court prosecutor.
2. Whether the trial judge erred in setting aside the dismissal order and proceeding to decide the case on the merits after being designated only to receive evidence on the motion for reconsideration.
3. Whether the trial judge erred in rendering judgment against the deceased Emilio Cano without ordering substitution of parties.
4. Whether the trial judge erred in not striking out evidence and in awarding back wages to Honorata Cruz.
5. Whether the CIR en banc erred in denying the motion for reconsideration.

RULING

1. No. The CIR is not bound by strict technical rules of procedure under the Industrial Peace Act ( Republic Act No. 875 ). Section 5(b) of the Act emphasizes that the CIR should use all reasonable means to ascertain facts speedily and objectively, without regard to technicalities. Thus, the CIR en banc acted within its authority in entertaining the motion for reconsideration filed by complainants’ counsel, even without the prosecutor’s intervention, to determine whether the complainants authorized the dismissal of their case.
2. No. While the trial judge technically deviated from the CIR’s internal rules by not forwarding findings to the en banc before reinstating the case, this procedural lapse did not cause material injury to the petitioner. The CIR en banc’s subsequent denial of the motion for reconsideration affirmed the trial judge’s actions. Moreover, the CIR is guided by justice, equity, and substantial merits under Commonwealth Act No. 103 , and the finding that Honorata Cruz’s dismissal was unjustified was supported by substantial evidence.
3. No. The respondents were sued as officials of Emilio Cano Enterprises, not in their individual capacities. The judgment against the deceased Emilio Cano, except for aspects personal to him, is enforceable against his successor in office, as the liability attaches to the position in the establishment.
4. No. The trial judge correctly considered the evidence in the case, as the reinstatement of the complaint as to Honorata Cruz revived the proceedings. The award of back wages was proper because her refusal to return to work was justified due to the absence of a stipulation on back pay at the time reinstatement was offered.
5. No. The CIR en banc did not err in denying the motion for reconsideration, as the trial court’s decision was substantively correct and the procedural issues raised did not warrant reversal.
The Supreme Court affirmed the CIR’s decision and resolution, with costs against the petitioner.